3) of the Income Tax Act, 1961 is annexed as Annexure-2. 8. With regard to above Arm Length Price Adjustment it is submitted that the aforesaid Arm Length Price Adjustment was bad and devoid of merits because for determination of aforesaid Arm Length Co. No.27/CTK/2018 Price Adjustment the Ld, TPO followed the TNM Method and whereas the JV followed